simplebooklet thumbnail

Practical FCPA and UK Bribery Act Compliance Concepts for C-Suite and Corporate Board Members

ANTI-BRIBERY  LEADERSHIP Practical FCPA and U.K. Bribery Act Compliance Concepts for the Corporate Board Member, C-Suite E...
Global AntiCorruption   Anti-Bribery Leadership Practical FCPA and U.K. Bribery Act Compliance Concepts for the Corporate ...
Global Anti-Corruption   Anti-Bribery Leadership By Thomas Fox and Jon Rydberg Edited by Nick Briere  Copyright    2013 Th...
TABLE OF CONTENTS  Page Number Who Should Read This Book  3  About the Authors  4  Preface  5  1. Why Comply with Global A...
Who Should Read This Book  If you    believe    your organization is compliant because   1  you provided training   2  you...
About the Authors  Thomas Fox, P rincipa l of TomFoxLaw and Author  Mr. Fox has practiced law in Houston for 30 years. He ...
Project Management Professional  PMP , and a Certified Internal Auditor  CIA . And, he holds three U.S. Patents and is a B...
P reface    P ut simp ly, the prospect of significant prison sentences for individuals should make clear to every corporat...
corruption anti-compliance     should be viewed, like quality and safety, as an equal business metric. Although compliance...
Chapter 1  Why Comply with Global Anti-Corruption Anti-Bribery Laws  The high volume of fines levied by the U.S. governmen...
underlying foundation in the organization   s Mission, Vision, Values, and Code of Conduct, and end with a continuous and ...
Chapter 2  Two Prevailing Laws     The FCPA and U.K. Bribery Act There is a growing focus on the part of worldwide governm...
bribe, to supervise a bribe, or to fail to report a bribe. In short, pretty much anything associated with bribery of a for...
Bribery Act . The legislation was initiated on recommendations from the British Serious Fraud Office  SFO  and, in many wa...
The business environment is changing and laws surrounding bribery, corruption, and ethics are growing in complexity, neces...
Chapter 3  How Do Such Laws Relate to Your Business  In order to design an effective anti-corruption anti-bribery program,...
                                                     Commercial purchase order invoice  with or without a contract  Fixed ...
If you    re a manufacturer, you might sell to a distributor at a reduced cost. This distributor will then likely sell the...
Remember, you    re responsible for running your business in a way that is compliant with the anti-corruption and anti-bri...
Chapter 4  Creating Your Anti-Corruption Anti-Bribery Program The underlying principles of every anti-corruption anti-brib...
The OECD Good Practice Guidance reads     Strong, explicit and visible support and commitment from senior management to th...
                          Remaining engaged and or involved in oversight of appropriate third party business partners  Dem...
Ownership - Individual responsibilities should be established in the company   s organization chart and throughout its job...
                                  A commitment to carry out business fairly, honestly, openly, and with transparency  A co...
How does a company decide what its standards and procedures should be  Well, by asking basic questions about the business,...
Recommended standards and procedures might, amongst others, include the following                                         ...
We recommend a balanced approach to training that may include some of the following methods of delivery                   ...
                        need to obtain corporate regulatory and partnership filings, a list of countries where the third p...
in little insight into this information. The    future    should really be an indication of perpetuity as well as providen...
A robust compliance program should include separate functions for auditing and monitoring. While unique in protocol, the t...
ability to prevent or detect fraud. The modern concept of    GRC     Governance, Risk, and Compliance  would suggest that ...
Chapter 5  Marketing Your Anti-Corruption Anti-Bribery Program A Compliance Department holds some degree of responsibility...
safety, so that compliance becomes an integral part of management   s everyday concern.    It is important to        make ...
our whistleblower program so that if they have an employee who sees something, they   ll feel incentivized to report it in...
Chapter 6  High Risk Areas to Watch You have arrived  You have created your compliance program in accordance with FSG    8...
approving the travel to the U.S. by the foreign governmental officials. These facts provided strong guidance to any compan...
                             The routine business it did have with the foreign governmental agency was guided by administr...
                  All costs must be paid for directly to the service providers     in the event that an expense requires r...
Distribution Risk As noted in Chapter 3, a common method of product movement includes the use of distributors. Distributor...
agents, imposing performance goals and objectives, or providing reimbursement for sales activity. Once a company identifie...
increasing, whether the standard discount range should be raised or lowered, and provides companies the ability to gauge t...
had been an actual bribe. The intent to bribe is permanently documented in that email. Now, think about the thousands, per...
There are several types of free or promotional products that need to be considered. First, are the promotional    trinkets...
done in that particular culture. What might be acceptable as commission in one country might not be in another. The import...
         You need to make sure that all monies, discounts, or gifts that are given are relevant to the nature of the trans...
Chapter 7     Leveraging Internal Controls to Mitigate High Risk Areas Internal control concepts aren   t always given the...
ethics, efficiency, accuracy, and compliance are continually put into practice. Internal controls will allow you to place ...
2. Provide necessary support to individuals of integrity who are facing unethical behavior. More specifically, internal co...
Treadway Commission. That is, internal controls should be designed to assist the organizations ability to                 ...
Third Parties               Always conduct due diligence of third parties prior to engaging in a relationship. Due diligen...
best interests. Internal controls are helpful for all members of an organization. Sure, they help manage a company   s ris...
Chapter 8  When the Government Comes Knocking Knock. Knock. You get a call one day and a representative of the Federal Gov...
positive response. However, just because counsel was retained by the organization, that does not permit the concealment of...
want the investigation to proceed. The investigation can go in multiple directions, but the two most likely courses that t...
potential legal ramification. In some cases, fines will be charged to the employees and officers responsible   these are f...
Chapter 9  What Does It All Mean  Paul McNulty   former Deputy Attorney General   often cites three questions he would ask...
overstated     because being imprisoned in a place like China is near the top of just about anyone   s list of things you ...
on an annual basis. Our Ethics Program is maintained by our Ethics Counsel and led by our CEO. She has a copy of the Code ...

Dear Jon, Joe, and Harry

 

I'd like to know more about how my company can improve it's compliance programs and how you can help us train all our employees - from the boardroom to the mailroom. Please also send me hard copies of your anti-bribery leadership book so I can distribute to my leadership. I've noted how many I need and to whom they'll be going to.


Company
Primary Contact
Title
Email
Telephone
Address:
Preferred Contact
How Can We Help?

   Put simply, the prospect of significant prison sentences for individuals should make clear to every corporate executive...